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Wednesday, July 24, 2024

PRIVACY POLICY UPDATED TO GDPR 679/2016 - rev.00 of 13.07.2018



Derwood srl based in Martellago (VE), Via Fornace, 2 C.F and P. Iva 01938130273 (hereinafter referred to as the "Owner"), as data controller, informs you according to art. 13 D. Lgs. 30.6.2003 n. 196 (hereinafter, "Privacy Code") and art. 13 EU Regulation n. 2016/679 (hereinafter, "GDPR") that your data will be processed in the manner and for the following purposes:

1) Object of the processing

Given the services and products offered by our organization, the Data Controller processes personal, identifying and non-sensitive data (for example the name, surname, home address, date of birth, social security number, email address, telephone number) you have communicated when requesting services to our organization and / or when defining contractual agreements and / or promotional initiatives and for the purposes set out below:

2) Purpose of the processing

Your personal data are processed:

A) Without your express consent (Article 24 letter a, b, c Privacy Code and Article 6 letter b, and GDPR), for the following Service purposes:

  • fulfill the pre-contractual, contractual and tax obligations arising from relations with you;
  • fulfill the obligations established by the law, by a regulation, by the community legislation or by an order of the Authority, (as for example in the matter of anti-money laundering);
  • for the keeping of the general accounts;
  • for management purposes (invoicing, possible document management, etc.);
  • for credit management;
  • for statistical analysis and quality control;
  • for insurance operations;
  • for technical assistance;
  • exercise the rights of the Data Controller, for example the right to defense in court.
  • allow the sending of newsletters, commercial communications and / or advertising material on products or services offered by the Data Controller and / or detection of the degree of satisfaction on the quality of what was done on your request;
  • for technical and functional access to the website;
  • for statistical purposes and website optimization.

B) Only with your specific and distinct consent (articles 23 and 130 of the Privacy Code and article 7 of the GDPR), for following purposes:

  1. Marketing and / or commercial: Send via e-mail newsletters, commercial communications and / or advertising material on products or services offered by the organization. Please note that if you are already a customer, we may send you commercial communications relating to services and products similar to those you have already used, unless you disagree (Article 130 paragraph 4 of the Privacy Code) to receive information, promotional, advertising and marketing material,
  2. Data processing to improve the services and not necessary for carrying out the operations indicated in point 2A, but aimed at improving the services requested, and in any case always obtained directly by the interested party. Requirements for the development of processes and services required by management systems and organizational models implemented, but not mandatory and not related to specific standards.

3) Mode and duration of the processing

The processing of your personal data is carried out by means of the operations indicated in art. 4 of the Privacy Code and art. 4 n. 2) GDPR and more precisely: collection, registration, organization, storage, consultation, processing, modification, selection, extraction, comparison, use, interconnection, blocking, communication, cancellation and destruction of data. Your personal data are subjected to both paper and electronic and automated processing.

The Data Controller will process personal data for the time necessary to fulfill the aforementioned purposes and in any case for no more than 10 years from the termination of the relationship for the purposes set out in point 2.A (except for other legislative requirements).

For the purposes referred to in point 2B, on the other hand, the Data Controller will process data for a maximum period of 2 years from the collection of data and / or from the end of contractual, commercial and communicative relations established after collection. In any case, the data will no longer be processed after the revocation of the consent of the interested party (except legal obligations).

Profilations: no data profiling is performed.


4) Access to data

Your data may be made accessible for the purposes referred to in art. 2.A) and 2.B):

  • To employees and collaborators of the Data Controller, in their capacity as data processors and / or process managers and / or system administrators;

  • To the technicians and / or collaborators for the administrative, fiscal, accounting and / or administrative management to fulfill specific legal obligations or for which external suppliers have been identified.

  • To companies or other legal entities, qualified and appointed pursuant to art. 28 of Regulation 679/16, for support activities including: management and development of communication, management and development of business processes and projects, communication and promotion systems, for storage of personal data. Access may be granted to third parties that provide services deemed necessary and / or useful by the owner to manage the activities of the company and the related support processes. The suppliers of the IT systems are reported among the suppliers; credit institutions, professional firms, companies that provide services on IT systems / platforms that the Controller deems useful to use, to companies that carry out outsourcing activities on behalf of the Data Controller, in their capacity as external data controllers.

5) Data communication

Without your express consent (according to Article 24 letter a), b), d) Privacy Code and art. 6 lett. b) and c) GDPR) and without prejudice to communications and disclosures made in implementation of legal obligations, the Data Controller may communicate his data for the purposes referred to in art. 2.A), in Italy and / or abroad (as indicated in the following points) to: our network of agents; factoring company; credit institutions; debt collection companies; credit insurance company; commercial information companies for the services requested; professionals and consultants; companies operating in the transport branch; technicians and collaborators appointed to provide the requested services / products, to Supervisory bodies, judicial authorities as well as to all the other subjects to

whom the communication is mandatory by law for the accomplishment of said purposes. To legal entities entrusted with the services referred to in this statement.

For the purposes referred to in point 2B, refer to your timely consent and for their communication and / or diffusion we will refer to the specific consent.

6) Data transfer

The management and storage of personal data will be carried out on servers located within the European Union of the Owner and / or third-party companies appointed and duly appointed as Data Processors. Currently our servers are located in Italy. The data will not be transferred outside the European Union. In any case, it is understood that the Data Controller, where necessary, will have the right to move the server location to Italy and / or the European Union and / or non-EU countries. In this case, the Data Controller hereby ensures that the transfer of non-EU data will take place in accordance with the applicable legal provisions, stipulating, if necessary, agreements that guarantee an adequate level of protection and / or adopting the standard contractual clauses provided for European Commission.


7) Nature of providing data and consequences of refusing to answer

The provision of data for the purposes referred to in art. 2.A) is mandatory. In their absence, we can not guarantee the services referred to in point 2.A). The provision of data for the purposes referred to in point 2.B) is optional.

You may therefore decide not to provide any data or to subsequently deny the possibility of processing data already provided: in this case, you will not be able to receive commercial communications and advertising material relating to the Services offered by the Data Controller. In any case, you will continue to be entitled to the Services referred to in art. 2.A).


8) Rights of the interested party

In your capacity as an interested party, you have the rights set forth in art. 7 of the Privacy Code and art. 15 GDPR and precisely the rights:


A) To obtain confirmation of the existence or not of personal data concerning you, even if not yet registered, and their communication in an intelligible form;

B) To get the indication:

  • Of the origin of personal data;

  • Purposes and methods of processing;

  • Of the logic applied in case of treatment carried out with the aid of electronic instruments;

  • The identification details of the owner, the managers and the designated representative pursuant to art. 5, paragraph 2 of the Privacy Code and art. 3, paragraph 1, GDPR; and the subjects or categories of subjects to whom the personal data may be communicated or who may become aware of it in their capacity as designated representative in the territory of the State, managers or agents;

C) To get:

  • Updating, rectification or, when interested, integration of data;

  • The cancellation, transformation into anonymous form or blocking of data processed unlawfully, including data whose retention is unnecessary for the purposes for which the data were collected or subsequently processed;

  • The attestation that the operations referred to in art. 8.A) and B) have been brought to the attention, also with regard to their content, of those to whom the data have been communicated or disseminated, except in the case where this fulfillment proves impossible or involves a use of means clearly disproportionate to the protected right;


D) To oppose, in whole or in part:

  • For legitimate reasons, the processing of personal data concerning you, even if pertinent to the purpose of the collection;

  • To the processing of personal data concerning you for the purpose of sending advertising or direct sales material or for carrying out market research or commercial communication, through the use of automated call systems without the intervention of an operator through email and / or through traditional marketing methods by telephone and / or paper mail. It should be noted that the right of opposition of the interested party, set out in point B), for direct marketing purposes through automated methods extends to the traditional ones and that in any case the possibility remains for the data subject to exercise the right of opposition also only partially. Therefore, the interested party can decide to receive only communications using traditional methods or only automated communications or none of the two types of communication.

  • Where applicable, you also have the rights referred to in Articles 16-21 GDPR (Right of rectification, right to be forgotten, right of limitation of treatment, right to data portability, right of opposition), as well as the right of complaint to the Guarantor Authority.


9) How to exercise rights

You can exercise your rights at any time by sending:

  • A registered letter addressed to: Ciesse srl, located in Martellago (VE), Via Fornace, 2.

  • An e-mail to the address:

  • A PEC

10) Minors

The services of the Data Controller are not intended for minors under the age of 16 and the Data Controller does not intentionally collect personal information about minors. In the event that information on minors were unintentionally registered, the Data Controller will delete them in a timely manner, at the request of users. For any need of treatment of minors, specific consent and authorization will be required from the person exercising parental responsibility and / or from the holder of parental responsibility (as required by Article 8 of Regulation 697/16).


11) Data Controller, responsible persons and data processors

The Data Controller is Derwood srl, located in Martellago (VE), Via Fornace, 2. The Data Controller is available at the addresses above. The updated list of responsible persons and / or data processors is kept at the Data Controller's headquarters.


12) Data Protection Officer

The Data Protection Officer (D.P.O.) has not been appointed.

13) Changes to this Privacy Policy

This Privacy Policy may change. It is therefore advisable to regularly check this information and refer to the latest version.


Martellago (VE), 01.10.2018 Derwood SRL


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